Supreme Court of New Hampshire

Appeal of Tradz, LLC

April 8, 2022

Summary

The Supreme Court of New Hampshire affirmed the Department of Safety’s denial of title applications, holding that the abandoned vehicle statute does not apply to vehicles repossessed at a lienholder’s request, to vehicles towed from a dealership without owner authorization, nor to a vehicle removed from out‑of‑state property. The court based its decision on a plain‑meaning construction of RSA 262:40‑a and the mutually exclusive nature of the repossession scheme in RSA 259:87‑a.